Coleman v. Dep't of the Navy, No. 19-3191, 2020 WL 5545543 (D.D.C. Sept. 16, 2020) (Berman Jackson, J.)

Coleman v. Dep't of the Navy, No. 19-3191, 2020 WL 5545543 (D.D.C. Sept. 16, 2020) (Berman Jackson, J.)

Re:  Request for video footage recorded on January 5, 2004 at Camp Lejeune Marine Corps Base in Jacksonville, North Carolina

Disposition:  Granting defendant's motion for summary judgment; denying plaintiff's cross-motion for summary judgment

• Litigation Considerations, Adequacy of Search:  The court holds that "[defendant's] affidavits show that the search undertaken by defendant was reasonably calculated to uncover responsive records."  "The search is described with reasonable specificity, and it identifies the search terms used, locations searched, and provides a rationale for each database and location searched."  "The agency avers that no other locations or offices were involved in [the case tied to missing video footage]."  Responding to plaintiff's argument "that because defendant effectively concedes that the Main Gate video did exist at some point . . . Navy's failure to produce the footage or to explain why it cannot do so establishes that the search must have been inadequate," the court holds that "'[t]he adequacy of a FOIA search is generally determined not by the fruits of the search, but by the appropriateness of the methods used to carry out the search.'"